Christopher Hicks, a qualified elector from neighboring Clermont County, has repeatedly challenged the Adams County voter registration of county prosecutor Aaron Evans Haslam, alleging that Haslam falsely claims to reside at a West Union apartment when he actually lives with his wife and children in Hamilton County. Hicks contends the apartment is a 'sham address' maintained solely to allow Haslam to hold elected office in Adams County. The board has twice denied Hicks's challenges based solely on its records without conducting the hearing required by state law.
The court rejected the board's res judicata defense, holding that Hicks's October 2025 challenge constituted a separate transaction from his earlier August challenge. As Lucci wrote, 'Every day that Haslam resides outside Adams County, if indeed he does, constitutes a continuing violation of Ohio's voter-registration and residency laws.' The court emphasized that the underlying factual question of Haslam's actual residence 'has never been adjudicated; the issue has continuously been cast aside.'
Most forcefully, the court declared that applying claim preclusion would 'reward the board for its failure to follow the statutory process' and would 'permit the board to expediently deny Hicks's challenge without holding a hearing and thereby avoid its statutory duty.' Lucci wrote that such an outcome would 'contravene the overriding public policy' requiring county officers to reside in the county they serve.
The case arose after Haslam was appointed Adams County prosecutor in July 2023, having registered to vote at the West Union apartment address just 46 days before his appointment. Hicks presented evidence suggesting Haslam's true residence is a $1.3 million home in Cincinnati where his wife is registered to vote, contrasted with the modest two-unit apartment building appraised at $132,100. Water usage data at the apartment, vehicle registrations in Hamilton County, and ethics filings disclosing that Haslam's wife and children reside in his household all supported Hicks's challenge that the prosecutor doesn't actually live at his registered address.
The board argued that its records showing Haslam's voter registration history, appointment documents, candidate petitions, and successful mail delivery to the West Union address were sufficient to deny the challenge. The court firmly rejected this reasoning as 'circular,' noting that the board 'essentially determined that Haslam resides at the West Union apartment address because its records say he does.' Lucci wrote that the board's records 'establish only that Haslam claims to reside in Adams County' but 'do not address the substance of Hicks's allegations and evidence that Haslam does not actually reside at his registered address.'
Under Ohio Revised Code Section 3503.24(B), election boards must hold a hearing when they cannot resolve a voter registration challenge based solely on their records. The court emphasized that such proceedings 'must result in a hearing resembling a judicial trial when the board cannot decide the matter solely on its records.' Video evidence filed by Hicks showed the board's October meeting lasted less than ten minutes, with members voting to deny his challenge without any discussion of the evidence he submitted.
The court also addressed the board's standing argument, holding that the 2016 legislative amendment removing the phrase 'of the county' from the statute now permits 'any qualified elector' statewide to challenge voter registrations. This represents a significant expansion of standing to challenge voter registrations beyond county boundaries. The court noted this change was a 'deliberate harmonization' by the legislature, not merely stylistic revision.